PRIVACY POLICY

IKO INTERNATIONAL, INC.

PRIVACY POLICY

Purpose of Privacy Policy

The purpose of the IKO International, Inc. (“IKO International”) Privacy Policy is to appropriately and safely manage and protect the personal data of customers and other data subjects (“Personal Information”), which IKO International collects, utilizes and processes during the ordinary course of its business.

IKO International is acutely aware of the need to protect and safeguard Personal Information in order to maintain the trust and confidence of its customers and those with whom it has business relationships and dealings.? To achieve and maintain this trust and confidence is of utmost importance to IKO International.? This importance makes vital the need for a Privacy Policy that enables you to know and understand what Personal Information IKO International collects and the purposes for which such Personal Information is processed and used.

IKO International shall implement and apply this Privacy Policy in accordance with the regulations of the General Data Protection Regulation (“GDPR”) and the applicable privacy laws and regulations of other jurisdictions, which shall include, if applicable, the jurisdiction of the California Consumer Protection Act of 2018 (“CCPA”).? Hereinafter, references in this Privacy Policy to “other jurisdictions” shall include the jurisdiction of the CCPA.

IKO International shall implement and establish company-wide awareness of the need to protect Personal Information, install suitable systems to protect Personal Information, and establish safety measures and principles to ensure the integrity and safety of Personal Information and prevent unauthorized access to, or loss, destruction, falsification or leaking of, Personal Information.

Personal Information that IKO International Collects

IKO International, as the controller, collects Personal Information only when it is needed to achieve and carry out its business objectives and purposes.? For example, IKO International collects and processes Personal Information in order to:

  1. Provide information about IKO International’s IKO products and services or those of IKO International’s affiliated companies.
  2. Obtain information with respect to the ordering and the purchasing of IKO International’s IKO products and services.
  3. Obtain or provide information with regard to the entering into agreements, subcontracts, and contracts, and fulfilling, managing, and terminating agreements.
  4. Provide or obtain information to create and maintain customer accounts, including payment and credit card information.
  5. Provide or obtain Personal Information in connection with offering technical support services and CAD data download services.? ?
  6. Provide or obtain information pertaining to product warranties or repair or replacement of products.
  7. Provide, obtain or disclose information to comply with the requirements and edicts of the law.
  8. Publicize and provide information about product exhibitions and sales promotions.
  9. Send and distribute publications, brochures and information on IKO International’s IKO products in response to people’s inquiries and requests.
  10. Communicate with research departments and institutions and their personnel.
  11. Engage in public relations sales promotion and related activities.
  12. Process and respond to job applications.
  13. Communicate and correspond with professional consultants, lawyers, accountants and engineers.
  14. Communicate and correspond with third-party affiliates.
  15. Communicate with employees regarding employer information and employment matters.
  16. Collect and obtain certain types of Personal Information in connection with any of the foregoing, such as, name, address, zip code, telephone number, fax number, email address, name of employer, type of business, occupation, language preference, IP address, browser information, and history access information and cookie data.

Processing of Personal Information and Consent to Provide Personal Information

IKO International processes Personal Information and in certain cases IKO International may contract with a third party to process Personal Information.? In either case, the processing is done for legitimate purposes and performed lawfully, fairly, and in a transparent manner and based upon at least one of the legal bases provided in Article 6 of the GDPR and the legal requirements of other jurisdictions.? Personal Information is kept for the length of time needed to achieve the purposes for which it is being kept for processing, unless a longer retention period is required or permitted by law.

IKO International takes care to properly identify you, as a data subject, and if you do not want your Personal Information to be collected and processed as set forth in this Privacy Policy, you may, at anytime, refuse and opt out to provide your Personal Information.? You should be aware, however, that if you do not allow IKO International to collect your Personal Information, IKO International may not be able to provide you with the full range of IKO International’s products and services and address your particular needs, interests and preferences.

Sharing of Personal Information

IKO International shares Personal Information with parties that provide third-party support services, such as postal and delivery services, maintenance services, public relations services, technical support services and CAD data download services and other data processing services. All such third parties shall be prohibited from using Personal Information, except to provide third-party support services to IKO International, and they shall be required to maintain the confidentiality of the Personal Information that is disclosed to, and shared with, them. ? ?

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IKO International may disclose Personal Information, if required to do so by law or to comply with legal process in litigation, or to comply with the demands or requests of government or public authorities or agencies or to protect and defend the rights or property of IKO International, or to protect the personal safety and rights of the users or providers of Personal Information.

IKO International may share Personal Information with IKO International’s affiliates (“Affiliates”).? When sharing Personal Information with IKO International’s Affiliates, such sharing and transfer of Personal Information shall be done pursuant to the regulations and rules of the GDPR and other jurisdictions. ? Affiliates of IKO International include the following entities:

1. Japan (Tokyo) NIPPON THOMPSON CO., LTD.

2. Japan (Tokyo) HASSEI SHOKAI CO., LTD.

3. Japan (Aichi Prefecture) NIPPON? DIC CO., LTD.

4. Japan (Gifu Prefecture) GOKURAKUJI KOSAN CO., LTD.

5. Japan (Mie Prefecture) SHINMIE SEIKO CO., LTD.

6. Japan (Mie Prefecture) NAGAHARA SEIKO CO., LTD.

7. The Netherlands (Rotterdam) NIPPON THOMPSON EUROPE B.V.

8. China (Shanghai) IKO – THOMPSON (SHANGHAI) LTD.

9. China (Shanghai) UBC (SHANGHAI) PRECISION BEARING MANUFACTURING CO.,?

? ? ? LTD.

10. China (Changshu City, Jiangsu Province) UBC (SUZHOU) BEARING CO., LTD.

11. Thailand (Bangkok) IKO THOMPSON ASIA CO., LTD.

12. South Korea (Seoul) IKO THOMPSON KOREA CO., LTD.

13. Vietnam (Haiphong) IKO THOMPSON VIETNAM CO., LTD.

14. Brazil (Sao Paulo) IKO BRASIL SERVI?OS EMPRESARIAIS LTDA.

15. Canada (Ontario) IKO THOMPSON BEARINGS CANADA, INC.

Transfers of Personal Information Outside of EU Countries

In some cases, it may be necessary for IKO International to transfer Personal Information to certain countries outside of the European Union, such as, the countries of Japan, China, Thailand, South Korea, Viet Nam, Brazil, Canada and the United States, in order to meet the data processing needs of IKO International.? In such cases, IKO International shall undertake to implement and adhere to a level of security and protection that is adequate to safeguard the Personal Information that is transferred in accordance with the protection standards required by the GDPR and other jurisdictions.

Protection of Personal Information

IKO International, acting as controller, at the time of determining the means for processing of Personal Information and at the time of the processing of Personal Information shall implement appropriate technical and organizational measures, which are designed to instill data protection principles that are effective in safeguarding the processing of Personal Information and in identifying the users and providers of Personal Information in accordance with the requirements of the GDPR (Article 25) and the privacy requirements or regulations of other jurisdictions.

IKO International strives to take appropriate security measures to protect against unauthorized access to, or alteration of, Personal Information. You, however, as a data subject, should be aware that despite IKO International’s best efforts, security measures cannot be made perfect or impenetrable; therefore, there can be no guarantee that your Personal Information will be kept completely secure.

Rights Concerning Personal Information

Under the GDPR, data subjects are provided certain rights with respect to the Personal Information that is collected and processed by IKO International.? Such rights include the right to:

  1. Receive information about, and obtain access to, your Personal Information that is collected and processed. (Articles 13, 14, and 15)
  2. Have your Personal Information rectified or erased. (Article 16)
  3. Place restrictions on the processing of your Personal Information upon the existence of certain conditions. (Article 18)
  4. Object to the processing of the Personal Information under certain circumstances applicable to the data subject. (Article 21)
  5. Choose not to let your Personal Information be subject to automatic collection and processing. (Article 22)
  6. Receive your Personal Information in a structured, commonly used and machine-readable format in order for you to transmit your Personal Information to another controller under certain circumstances without hindrance from IKO International.? (Article 20)

Similar rights may be provided to data subjects and consumers concerning the collection and use of their Personal Information in other jurisdictions.? Such rights shall be honored by IKO International.

If you, as a data subject, want to exercise any of the foregoing rights or you are not satisfied with the way that IKO International has collected and processed your Personal Information, you can contact the IKO International’s Data Protection Officer listed under the “Contact Information” section at the end of this Privacy Policy

Children’s Privacy

IKO International does not knowingly collect and process the Personal Information of children under 16 years of age or a lower age that may be applicable in a particular Member State of the EU, but which cannot be under 13 years of age.? IKO International will likewise adhere to age restrictions that may be imposed in other jurisdictions.? Upon discovering or being notified of usage of IKO International’s website by an underage child, without the consent or authorization of the child’s parent or guardian, IKO International will take immediate steps to delete the Personal Information that was provided by the child.

Changes to Privacy Policy

From time to time, IKO International may make changes to this Privacy Policy to accommodate and comply with new technologies, industry practices, regulatory requirements and changes in the law.? Unless you are notified otherwise, these changes will become effective upon being posted on IKO International’s website.? If certain changes are material and significant, IKO International will obtain your consent to such changes.

Links to Other Websites and Use of “Cookies”

Links

The IKO International website may have a link or links to other sites.? IKO International does not control and cannot be held liable for how third-parties protect personal data.? Consequently, users of the IKO International website should be aware that when they leave the IKO International site and go to a third-party site, they must carefully read the third-party’s privacy policy to determine how it collects, processes, and protects the personal data of the user.

Cookies

IKO International may use “cookies” in its website in order to make the website work more efficiently in recognizing the user’s device and to remember information about the user’s visit to the IKO International website and to track website activity.? Overall, cookies are meant to enhance and make more personal your website experience.

Cookies are small text files that the web server passes to the user’s web browser (e.g., Google Chrome, Internet Explorer, Mozilla Firefox and Safari).? The web browser will allow you to manage and control your cookies preferences by changing your browser settings, which will include your ability to accept, refuse or later opt-out of the cookies.? You should bear in mind, however, that if you block or reject cookies, your IKO International website experience will be impacted such that you will not be able to obtain full access to all of the functions and contents of the IKO International website.

Opt Out and Unsubscribe from Third-Party Communications

IKO International respects your privacy and gives you the opportunity to opt out of, and unsubscribe from, receiving communications from third-parties that provide support to IKO International.? You may opt out of receiving any or all communications from such third-parties by contacting IKO International at the contact information shown below.?

E-mail Communications

From time to time, IKO International may contact you by email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, or other communications in order to keep you informed and to improve IKO International’s products and services.?

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If you want to stop receiving such email communications from IKO International, you may opt out of receiving such communications by clicking the UNSUBSCRIBE button in the IKO International website.

Contact Information and Effective Date of Privacy Policy

If you have any questions, concerns or complaints about the manner in which IKO International collects and processes your Personal Information, the information for you to contact IKO International for any such reason or purpose is as follows:

Company: ? ? IKO International, Inc.

? ? ? ? 91 Walsh Drive

? ? ? ? Parsippany, New Jersey 07054 U.S.A.

Website: ? ? http://ikont.com

Telephone: ? ? +1-973-402-0254

Email: ? ? [email protected]

Data Protection Officer:? ?

(name)

Effective Date of Privacy Policy:? March 1, 2020

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